An alternative to keeping both data sheets, however, is provided for in
29 CFR 1910.1020. Under
paragraph (d)(1)(ii)(B) of this standard employers may discard
material safety data sheets if some record identifying the substances u
sed, where it was used and when it was used is retained for at least 30 yea
rs. Therefore, an employer may discard the original data sheet and retain o
nly the new data sheet if a record
on the original formulation is maintained.

So…. It sounds like I can discard old versions of MSDS
s if we have “some record identifying the substances used, where it w
as used and when it was used” and retain THAT for at least 30 years.&
nbsp;
I will have to determine whether I think we have that or not, I believe we
do now that we are a GMP operation, but perhaps not before our GMP days.

I would still be interested in knowing others take on this a
nd how they handle it.

A debate has come up within our organization concern
ing the retention of MSDSs. I have been saving old copies of MSDSs fo
r which new revisions have been issued. My understanding is tha
t this would be proof that we did have the MSDS on
file if an employee claimed twenty years later that they were exposed to a
chemical and said we did not provide them with adequate information.
I planned on keeping them for thirty years.

Others in my organization feel I may be wasting my t
ime. They feel I should be throwing out older versions and only retai
ning the latest copy particularly if the revisions were not significant. They do agree however, that I should be
keeping old MSDSs for chemicals for which we discontinue use.

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